ML20140E520

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Provides Response to Questions Asked in 970527 Memorandum & Order Re Denial for SRO license,55-20726-SP
ML20140E520
Person / Time
Site: Turkey Point, 05520726  NextEra Energy icon.png
Issue date: 06/06/1997
From: Tetrick R
AFFILIATION NOT ASSIGNED
To: Bloch P
Atomic Safety and Licensing Board Panel
Shared Package
ML20140E495 List:
References
SP, NUDOCS 9706120106
Download: ML20140E520 (18)


Text

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DOCKETED USNRC To: Peter B. Bloch, Presiding Officer Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission El JUN ~9 A9 :01 Washington, DC 20555 0FFICE OF SECFETARY Subject Ralph L. Tetrick DGCKETlH3 & 5LRVICE BRhHCH Denial of Application for SRO License Docket No: 55-20726-SP Date: June 6,1997 On May 27,1997, the Presiding Officer issued a Memorandum and Order for answers to questions relevant to Question #63. The following is rny response to the questions asked in said letter:

Quostion #1: of the memorandum and Order, the Presiding Officer states that my original discussion was directed to actions other than 'Immediate Actions'. If the Presiding Officer will refer to my original request on question #63 he will see that I contend that answer 'a'is also and 'Immediate Action' and therefore correct. Question #63 does not specify a specific ONOP and I contend that several ONOP's and ARP's could apply. They are as follows:

A) 3-ARP-097.CR - Control Room Annunciator Response (the ARP's are considered ONOP's as defined in 0-ADk 211 - Emergoncy and Off Normal Operating Procedure Usage - see attached page 9 of 0-ADM-211). The immediate action for 3-ARP-097.CR is to acknowledge the alarm, then refer to the correct Annunciator Panel. For Annunciator G-915 the response is to verify the alarm via Recorder R-1418. For Annunciator H 1/1 the response is to verify the alarm via levelindicator Ll-3-651 with corrective action to refer to 3-ONOP-033.1 or 3-ONOP-033.2 if applicable. (See attached pages of 3-ARP-097.CR).

B) 3-ONOP-033.1 - Spent Fuel Pit (SFP) Coo' ling System Malfunction - The immediate Action in the ONOP is: Verify Annunciated Alarm is Valid (see attached page of 3-ONOP-033.1).

C) 3-ONOP-033.2 - Refueling Cavity Seal Failure. The immediate Action for this ONOP is:

Sound Containment Evacuation Alarm (see attached page of 3-ONOP-033.2).

Since no specific ONOP is named, I contend that answer 'A'- Verify Alarms by checking containment sump level recorder and Spent Fuel Level Indication is an 'Immediate Action' with regard to 3-ARP-097.CR and 3-ONOP-033.1 and this would also be correct.

Question #2 you ask what provision would allow me to verify the alarms? The 'Immediate Action' of 3-ARP-097.CR and 3-ONOP-033.1 Require me to verify the alarms, also, FP&L's Management expectations and training reinforce this action (see attached procedures and FP&L's letter to the NRC). You also ask what I would do in the 20 seconds? I would refer to R-1418 and LI-3-651 as stated above.

The Presiding Officer also asks what would persuade me not to take the required 'Immediate Actions' l after verifying the alarms? My response is that verifying the alarm is an immediate Action. My original contention was that verifying the alarm was as much of an 'Immediate Action' as ' Sounding the Containment Evacuation Alarm', and that any and all corrective actions would be performed upon verification of the alarms.

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9706120106 970606 PDR ADOCK 05000250 0 PDR

The Presiding Officer continues this train of thought by asking what Supervisory approval, if any, I would seek and what records would I create. Since I contend that I was performing 'Immediate Actions'per 3-ARP-097.CR and 3-ONOP-033.1, the following would be perfctmed: The ANPS/NPS would be informed upon receipt of any alarms and their status ie. cleared or locked in, he would then be informed of their verification and of any corrective actions performed. After all necessary corrective actions were performed the incident would be recorded in the RCO narrative logs. This would include the alarms that came in, the verification of the alarms, the actions taken to correct the condition, any procedures referred to or entered (ARP's or ONOP's) and all pertinent information conntcted with the incident.

Question #3 the Presiding Officer asks if any changes to procedures are required with respect to

'Immediate Actions', as an Operator I do not feel that a procedure change is required, I fr.el that the conditions of question 63 could apply to several different procedures and therefore both answers A and ,

B are correct. l The Officer also asks what principles govem the performance of 'Immediate Actions *? A NRC Licensed Individualis responsible for taking timely and proper action so as not to create or cause a hazard to

  • safe Operation of the facility' etc. - refer to 0-ADM-101 (Procedure Writers Guide) and 0-ADM-200 ,

(Conduct of Operations) for explanation of timely (ie. Immediate Actions) and proper actions. '

This res ectfully concludes my response to your letter dated May 27,1997.

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RalptYL Tetrick 18990 S.W. 270 St.

Homestead, FL 33031 (305) 247-6364 1

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Procedurj No.: Procedur2

Title:

Page:

9 Emerg:ncy and Off-N:rmal Operating Approd Date:

0-ADM-211 Procedure Usage 10/8/96 4.9 Placekeepine Aids Methods used to help the operator locate important information during performance of a procedum.

4.10 Prompt Action i I

Steps to be performed without delay by procedure after the completion of the immediate Action Steps. _

l 4.10 Ruptured

' Refers to any steam generator (S/G) with demonstrated primary-to-secondary leakage in excess of chargine pump capacity such that Satety injection is or was required to maintain Reactor Coolant System inventory.

4.11 S/G Tube Leak Any steam generator with demonstrated primary-to-secondary leakage which is less than charging pump capacity.

4.17 Annunciator Response Procedures

.4.12.1 Specific Off-Normal Plant Proceduree which= provides the operator with the guidance to respond to plant annunciator panel alarmu l

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proc:eurs no.: proc. cur. Titl@: Pag 3:

Approvo Date;  !

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3- ARP.097.C H Control Room Annunciator Response 12/29/93 l i

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1.0 PURPOSE 1.1 This procedure provides instructions and guidance for resolving alarm conditions that are received on the Unit 3 Control Room Annunciator Panels.

1.2 This procedure provides instructions and guidance for the loss of all annunciators on the unit, single or multiple panel (s) or a single j annunciator.

. 2.0 SYMPTOMS n

i 2.1 Annunciator window alarm.

f 2.2 Annunciator panel blacked out.

. 2.3 Annunciator window blacked out.

3.0 AUTOMATIC ACTIONS 1 l 3.1 Refer to annunciator panel Attachments 1 through 11.

l C AUTIO N The NPS shall consult EPIP-20101, Duties of Emergency Coordinator, Table 1, in the i I i event of loss of most or all Control Room Annunciators for possible event classi6 cation.

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NOTES

.I I. . _ . _ . l

! I The annunciator panel attachments indicate appropriate operator action for

.

  • I I Control Room panel annunciators. The actions listed are intended to be a guide ,

g for operators in responding to single annunciators and not intended to be a g .

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. substitute for good judgment based on thorough understanding of plant I conditions andequipment. l I

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  • Many off-normal plant conditions will result in several annunciators lighting I I almost simultaneously. In such a case, operators are expected to respond to the ,

root cause of the problem and maintain the unit in a safe condition IAW l l

. applicable off-normal and emergency procedures. This action may not .

I necessanly correspond to that of the attachments. l

. t._._._.._._._._._._.._._._._._._._._._._._._.1 i 4.0 IMMEDI ATE ACTIONS 4 4.1 Acknowledge the alarm.

  • 10GKletidt/ct

Procedur2 No.: Procecure Titu: Pag; 8

Approva 0112 3-ARP-097.CR Control Room Annunciator Response 11/1/96 5.0 SUBSEOUENT ACTIONS

..._....._..-)

ANNUNCIATOR RESPONSE GUIDELINES l l

1) Unit ANPS/NPS SHALL be made fully aware / cognizant of all Annunciators at all I times (whether they have cleared or are locked in). I I i
2) RCO- Upon receipt of an annunciator, take immediate corrective actions as 1

necessary, informing ANPS of any corrective actions. l l 1

3) Daily Annunciator Response Procedure Usage:

1 I

For expected alarms such as ISC working in Racks, actual opening of l l

. ARP's is not required. '

I I For common or frequent alarms (WBP, Blender Deviation) use of the ARP is l l

. required for the first annunciation on the particular shift for the day.

I Subsequent annunciation does not require ARP consultation.

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For ALL other alarms the ARP SHALL be consulted as well as any other '

I I applicable procedures.

l._._._._._._._._._._.._._._._._._._._._._._._.J 5.1 Annunciator on Panel A 5.1.1 Perform Appropriate Attachment 1, Page 15 5.2 Annunciator on Panel B 5.2.1 Perfonn Appropriate Attachment 2, Page 69 5.3 Annunciator on Panel C 5.3.1 Perform Appropriate Attachment 3, Page 123 5.4 Annunciator on Panel D ,

5.4.1 Perform Appropriate Attachment 4, Page 177 5.5 Annunciator on Panel E 5.5.1 Perform Appropriate Attachment 5, Page 231 5.6 Annunciator on Panel F 5.6.1 Perform Appropriate Attachment 6, Page 285 5.7 Annunciator on Panel G 5.7.1 Perform Appropriate Attachment 7, Page 339

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froC3@ur@ No.; Proc @@ure htlJ:

391 Approval Date; f Control Room Annunciator Response 8/6/92 3 ARP 097.CR l

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INVESTMENT PROTECTION G 9/5 j BLUE G45 ATTACHMENT 7 ,

Page 53 of 54 l 1 l l CNTMT Panel G l 2 l l SUMP '

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4 _ ___

1 234 56789 ,

DEVICES: SETPOINTS:

4 R-1418 30"

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(unit 4 VPA) ,,

4 OPERATOR ACTIONS:

1. Verify alarm by checking the following_
a. CNTMT sump recorders R-1418 (unit 4 VPA), R-6308A/B, and DDPS point

- DDPSA102-3.

2. Corrective actions:
a. Verify proper operation of the containment sump pumps.
b. Pump c
c. own the sump as required.Momtor RCS parameters for indications
d. Perform 3-OSP-041.1 to determine the RCS leak rate, if applicable.

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l If annuncistor is 005, refer to 0-ADM-2 M.

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CAUSES: "

. 1. RCSleak. -

2. Instrumentmalfunetion.

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REFERENCES:

1. - FPL DWG 5610-M-12 o

b e 15/JGK/dt

I droceurs sitie; Gr0CeQuf e NO - Page: 393 3 ARP 097.CR Control Room Annunciator Response **Y[i8NI3 BLUE INVEST. TENT PROTECTION HE H1 ATTACH 3ENT 8

-Page 1of54 1C l l l Panel H syp

! 2- l l l l l 3 l I LO LEVEL 4 l l 5 I I -

6 , l l l 1 234 5678 9 DEVICES: SETPOINTS:

Level actuator at 56'10" north end of SFP LT-3 651 OPERATOR ACTIONS:

1. Verift alarm by checking.the followingt a.-~"' LL3-651WPB) - _
2. Corrective actions:
a. Dispatch operator to check:

(1) Spent fuel level indication LY-3-651 (behind VPB)

(2) Locallevel at the SFP.

(3) Power to LT-3-651 (LP-50. Bkr 19 - east wall of cable spreading room.

b. Refer to 3-ONOP-033.1, SPENT FUEL PIT (SFP) COOLIh G.
c. IF in a refueling configuration with the SFP transfer tube open, THEN l terminate refue Ling operations and refer to 3-ONOP 033.2. Refueling Cavity  !;

Seal Failure System Malfunction for cavity seal failure '

required actions.

d. - Refer to TS 3.9 for additional actions.

. NOTES I I

If SFP cooling has to be secured, monstor SFP temperature per Attachment le

. 3-OP-033. notsty Reactor Engineersng. I I

l le If annunciator ss OOS. refer to 0-ADM.2 M.

i...._.._._._._._..._.._..._._.._.....a CAUSES:

Actual low level in SFP (Evaporation. leakage, or SFP system valve misalignment)

1. l
2. Loss of power to LT 3 651
3. Instrumentation failure

REFERENCES:

1. FPL DWG 5613-M-3033 Sh 1
2. Tech. Spec. Section 3.9  !

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Turkey Point Nuclear Plant .

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Title:

Spent Fuel Pit (SFP) Cooling System Malfunction Safety Related Procedure Responsible Department: Operations Revision ApprovalDate: 10/31196 Periodic Review Due: 10/20197 R TSs 86-1638, 88-0039. 90-0086E. 90-2228, 91-2484, 92-0867P, 92-1250P

! RTSs 92-1358P, 93-0060P, 95-0930P, 96-1068P PC/Ms89-272,92-031 A

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Proceoure No.: } Proceoute T41e: Page:

Spent Fuel Pit (SFP) Approvat Date:

3-ONOP-033.1 Cooling System Malfunction 10/31M6 1.0 PURPOSE 1.1 This procedure provides instructions for response to off-normal conditions of the Spent Fuel Pit (SFP) and the SFP Cooling System including SFP High/ Low Level and High Temperature.

2.0 SYMPTOMS .

2.1 Annunciators 2.1.1 H 1/l, SFP LO LEVEL 2.1.2 H 1/2, SFP HI TEMP 2.1.3 H 1/3, SFP HI LEVEL 2.2 Indications 2.2.1 High/ low SFP, as indicated on LI-3-651, (VPB) or by local I visual inspection using level placard located at the Northwest I I

corner of the SFP (normal level is 56'- 10"- 57'2")

2.2.2 Low SFP Cooling Pump Discharge Pressure (PI-3-651B; 651 A) 2.2.3 SFP Filters High AP (DPI-3-151 A, B, C), AP across filters should be

<10 psid 2.2.4 Low SFP Skimmer Pump Discharge Pressure (PI-3-671 A) 2.2.5 SFP Skimmer Pump Filters High AP (DPI-3-150A, B, C), AP across l filters should be <10 psid 2.2.6 SFP Demineralizers High AP (INLET PI-3-655A -

OUTLET l PI-3-655B) (N/A if RWST is on Recirc through the SFP Demin) AP '

acmss Demin should be <35 psid 3.0 AUTOMATIC ACTIONS 3

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. NOTE .

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Bkrs for SFP pps are located inside Unit 3 SFP Hx Room. l l

l a. 3A SFP Pp Bkr 3P212A 1, l b. 3B SFP Pp Bkr 3P2128 (Power supply to 3NP212 panelis fed l l from Bkr30309) i._._._._._._._._._._._._._._._._._._._._._._._.;l 3.1 Possible SFP Cooling Pump Breaker trip on overload.

3.2 Possible SFP Skimmer Pump Breaker trip on overload. (Bkr 30777) 4.0 IMMEDIATE ACTIONS l

4.1 Verify annunciated alarm is valid.

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Florida Power & Light Company a

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Title:

5 Refueling Cavity SealFailure 4

Safety Related Procedure Responsible Department: Operations Reviewed by PNSC: 93-149 j

Approved by Plant GeneralManager: 6/24/93

l. Al20/96

! Periodic Review Oue:

! RTSs 87-03779,88-2210,89-1021,90 2205,91 1565P,91-0561T RT5s 92-12519, 92-10329, 92-1358P, 93-0930P i PCIM 89-332,92-031

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  • l Pro (scsr e Tit'e. Gagg inrocgcyre No .

Approvai Datt 3 ONOP 033.2 Refueling Cavity Seal Failure 10/21/92 l I

i 3.0 AUTOMATIC ACTIONS 3.1 Possible containment ventilation isolation due to high containment radiation levels.

3.2 Possible Control Room ventilstion isolation due to high con tainment radiation levels.

4.0 IMMEDIATE ACTIONS 4.1 Sound containment evacuation alarm.

5.0 SUBSEQUENT ACTIONS C AUTIONS e With an irradiated assembly full up on the manipuistor crane and maximum refueling cavity seal leakage. the refueling bndge radiation levels will reach 10 Remlhrin about 22 mirmtes.

  • As reactor internals are exposed. airborne contamination levels in containment willincrease.

5.1 Refueling Operator (s) in Containment 5.1.1 WHEN informed by H.P. that any of the following occurs, THEN exit the containment building immediately:

1. Area radiation levels exceed 10 Rem /hr OR
2. Airborne contamination levels exceed 1000 times pre-event level OR l
3. Cumulative dose exceeds 10 Rem whole body or 50 Rem to the thyroid.

g..........._._._..._..........._._._._._.....-.., NOTE .

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Steps S. I.2 and 5.1.3 should be performed at the same time. l l l

i. ._._._._._._._. . . ._. . ._._... ._._._._._.3 5.1.2 1E an irradiated fuel assembly is in the fuel transfer car, THEN lay assembly down AND transfer assembly to the Spent Fuel Pool.

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- - - _ ____ . - _ _ _ - _ -_ _ __ _ 3

l-l MAY 1 1997 i L-97-126 5:FDL.

i Stuart A. Richards  ;

Chief, Operator Licensing Branch, NRR l U. S. Nuclear Regulatory Commission l White Flint North 11555 Rockville Pike ~

l Rockville, Maryland 20852 j

Dear Mr. Richards:

)

Re: Rainh Tetrick Exam Aconal J In reference to information requested by Mr. R. Croteau related to Ralph Tetrick's NRC Senior Reactor Operator (SRO) License Exam administered June 1996, Florida Power & Light Company (FPL) has the following positions:

1. A personal letter was sent by our employee Mr. Brian Stamp l representing his personal opinion about Question 063 of the  !

NRC SRO Exam. Since this was a personal letter, not on a  !

company letterhead nor signed by an officer of the company, l it does not represent the position of FPL.

2. If the question is interpreted to be asking for an Off Normal Operating Procedure (ONOP) immediate. action, response (b) is correct. Question 063 however, asks for an IMMEDIATE ACTION without specifying that it is looking for the ONOP IMMEDIATE ACTION. The only way this is implied in the question is by the words "IMMEDIATE ACTION" being capitalized, which is the ,

I format used in the ONOPs.

If the question is interpreted to be asking for an immediate.

action for the receipt of an annunciator, response (a) is correct. Management's policy and expectation of operators is to validate all alarms by checking appropriate instrumentation prior to taking action. Additionally, the Annunciator Response Procedure (ARP) instructs the operator to verify the alarm with the indications contained in response (a). See the attached ARPs for the two annunciators listed in Question 063.

It is FPL's position that the best answer to the question is response (b), but that the question could be interpreted such that response (a) is also correct. As a result, Question 063 as written, has two possible correct answers.

A an FPL Group company

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L-97-126 l Page 2 '

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3. Management's policy and expectation of operators to validate all alarms by checking appropriate instrumentation prior to taking action has been reinforced in the simulator training program. This policy provides assurance that the appropriate actions are being taken for valid plant conditions and does '

not result in an operator failing to follow an appropriate- '

procedure. -

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Very truly yours, R. J. Hov i Vice President  !

Turkey Point Plant OIH. i i

cc: T. A. Peebles, Chief, Operations Branch, Region II, USNRC .

L. A. Reyes, Regional Administrator, Region II, USNRC i Documenr Control Desk,.USNRC ]

T. P. Johnson, Senior Resident Inspector, USNRC, Turkey Point Plant ]

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8 roc:rsure Noa Procgoura f att3: '

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Pag 3; 393 3 ARP 097'.CR Control Room Annunciator Response - *T[10Ih*3  !

1 BLUE INVESpENTPROTECTION H 1/1 H1 A'ITACHAENT 8 I 1

Page lof 54 2


PanelH SFP i 3l l LO LEVEL 4l l

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5l l 6l l '

1 23 4 5678 9 DEVICES: SETPOINTS: '

Level actuator at 56'10" l north end of SFP ,

LT-3-651

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2. Corrective actions:
a. Dispatch operator to check: ,

. (1) Spent fuellevelindication LY-3-651(behind VPB) ,

I (2) Locallevelatthe SFP.

(3) Power to LT-3-651 (LP-50. Bkr 19 - east wall of cab eading room.

b. Refer to 3-ONOP.033.1, SPENT FUEL PIT (SFP) COO
c. E in a refueling configuration with the SFP transfer tube o xn, THEN terminate refueming operations and refer to 3-ONOP-033.2,lefueling Cavity  !

Seal Failure System Malfunction for cavity seal failure rec uired actions.

d. Refer to TS 3.9 for additional actions.

I NOTES i i E

If SFP cooling has to be secured, monitor SFP temperature per Attachment 3 of le 3-OP-033, notify Reactor Engineering. I I

If annunciatoris 005, refer to 0-ADM-214 g j le -

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.. ._._._._._._._._._._._._._._._._._._._._._._.a i CAUSES:

1. Actual low level in SFP (Evaporation, leakage, or SFP system valve misalignment) l
2. Loss of power to LT 3 651
3. Instrumentation failure

REFERENCES:

l

1. FPL DWG 5613-M-3033 Sh 1
2. Tech. Spec. Section 3.9 e 'E JG< : =c sse 0

-1 l

Procesura No.; Proc 35ure htl3: pagg, 391 1

- - Approm onte: -!

3.ARP 097.CR Control Room Annunciator Response 8/6/92 BLUE INVESTMENTPROTECTION ' G 9/5

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G45 A'ITACHMENT 7 Pa e 53 of 54 1 l l

'anelG CNTMT 2 l l SUMP 3 l l g ggt 4

5 6 ,.

1 234 5678 9 .

DEVICES: SETPOINTS:

R-1418 30" (unit 4 VPA) ,

OPERdTj(iFICTIQNS:'[inythe 17 Ve6fy' alarm'b c6ick follo~~~in~g:

w GNTMT. 5ngrec5rt@r1U836I6it3fA] R-6308A/B, and DDPS point DDPSA102:3. .

. 2. Corrective actions:

a. Verify aroper operation of the containment sump pumps.  :
b. Pump c own the sump as required.
c. Momtor RCS parameters for indications ofleak,if applicable.
d. Perform 3-OSP.041.1 to determine the RCS leak rate, if applicable.

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y. .-......-...-.-.-.-. y ... .-.3
  • j ,i If annunciatoris 005, refer to 0 ADM-214. l l

t......-.....-.........-..............-.-.-...;

CAUSES:

1. RCSleak. -
2. Instrument malfunction.

REFERENCES:

1. FPL DWG 5610-M-12 e 15/JGK/dt i

. _ . _m - _ _ _ . - _ _ _ _ _ - . _ . _ . . . _ . _ _ . _ _ _ _ _ _ . . _ _ _ _ _ _

To: Peter B. Block, Presiding Officer l Atomic Safety and Licensing Board  !

-U.S. Nuclear Regulatory Commission  !

Washington, DC 20555 j

~

Subject:

NRC Staffs' motion for reconsideration in the matter of l' Ralph L. Tetrick.

1 It'is expected that the Licensed Operators at Turkey Point verify plant. conditions when-one or more annunciators are received in tne control room _ prior to taking corrective actions. -

In'the case of Question #63, I fully expect the Operators to verify the decreese in the Spent Fuel Pool level and the increase in the Containment Sump level by the indicators located within .

the surveillance area of the control room. This action would only_take seconds and could preclude erroneously sounding the containment _ evacuation alarm. During refueling outages, there are numerous jobs going on simultaneously inside the containment.

Requiring all personnel to evacuate the area unnecessarily could pose a larger safety hazard than would the increased radiation levels at the refueling stations for those few seconds. In i addition, the Training Departments: question bank has been revised concerning the correct. answer to Question #63.

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r$NnL)lcIal i B'rians7. Stamp -

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l Acting Operations Supervisor l Turkey Point Operations Department  !

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Pago:

Proceoure

Title:

Approval Date:

  • Proceoure No.:

4/4/96

, Procedure Writer's Guide _

0-ADM-101 5.4.19 (Cont'd1

6. Spaces shall be provided for recording appropriate by the the following informa Operations determined to be when Supervisor:
a. Date/ Time Started
b. Initials for performing each step
c. Date/ Time Completed
d. Performed By (
e. Reviewed By 5.4.20 Immediate Actions 1.

This section contains those Instructional referencingSteps the which writtencan be from memory without performed This section specifies the actions for operation of procedure.

controls and/or confirmation of automatic actions th performed in a timely manner in order to:

a. Prevent personnelinjury
b. Prevent equipment damage and mitigate their of conditions
c. Stop the degradation consequences occurred and that actions have
d. Verify that , automatic equipment is operatmg as designed Prevent unnecessary activation of protective features such as e.

Reactor Trip or Safety Injection

f. Assure that the reactor is in a safe condition
g. Notify plant personnel of the nature of the off-normal or emergency condition h.

Determine that the reactor coolant system pressure boundar is intact i.

Determine that a heat sink for decay heat removal is available and functioning properly I

6

/1:3/ DEW /tr

Proceoum No.: ProcedurJ True: Page:

32 i

, Approval Date:

0-ADM-200 Conduct of Operations 10/8/96 l l

l 5.1.14 Operation of mechanisms and apparatus other than controls that may i indirectly affect the power level or reactivity of a reactor shall only be I accomplished with the knowledge and consent of a licensed operator. l

[ Commitment - Step 2.3.1) i 5.1.15 Operations Department personnel shall respond to instrument )

indications until the instruments are proven to be incorrect.

5.1.16 NRC licensed individuals shall observe all applicable rules, i regulations and orders of the NRC, whether or not stated in the license. [ Commitment - Step 2.3.1) 5.1.17 NRC licensed individuals are responsible for taking timely- and proper actions so as not to create or cause a hazafd~io ~" safe' operation of the  ;

facility" (i.e., action or activities, including failure to take action, '

related to the facility which could have an adverse affect on the health and safety of the public, plant workers, or the individuals).

Examples of situations which could result in violations include:

1. Noting a serious violation of procedural requirements and not  ;

taking corrective action. l

2. Unauthorized bypassing of required reactor safety systems.
3. Defeating alarms which have serious safety significance.
4. Unauthorized abandoning of reactor controls.
5. Knowingly taking actions that violate Technical Specifications Limiting Conditions for Operation. [ Commitment - Step 2.3.1]
6. Failure to make Equipment Out of Service (EdOS) Book entries on all IST components when maintenance is performed.

[ Commitment - Step 2.3.9) 5.1.18 The Shift Communicator shall hold or have held an RO or SRO license at Turkey Point or some similar facility. He shall have no other collateral duties that would be in conflict with his duties as Communicator (e.g., Fim Team i.cader, First Aid Team Member, etc.).

5.1.19 Operators on shift are responsible for adhering to plant Technical Specifications, plant operating procedures, and NRC regulations.

[ Commitment - Step 2.3.21 5.1.20 IF any Limiting Condition for Operation (LCO) is not met AND no remedial action is specified in the Technical Specifications. TilEN the reactor shall be shutdown. [ Commitment - Step 2.3.5)

  • lt3/MBS. .ttc/bc